## Facts

- Jeffrey Gorman, a paraplegic, was arrested by Kansas City police and transported in a van not equipped to accommodate a person with a spinal cord injury.
- During transport, Gorman suffered serious injuries that limited his ability to work full time.
- Gorman sued Kansas City police officials and officers under ADA § 202 and Rehabilitation Act § 504, alleging disability discrimination based on inadequate policies for arrest and transportation of disabled individuals.
- A jury awarded compensatory and punitive damages; the district court set aside the punitive damages as unavailable under ADA § 202 and Rehabilitation Act § 504.
- The Eighth Circuit reinstated punitive damages, reasoning that federal courts may award “appropriate relief” absent contrary congressional direction.
- The Supreme Court granted review to decide whether punitive damages are available under ADA § 202 and Rehabilitation Act § 504.

## Issues

1. Whether punitive damages are available in private suits under ADA § 202 and Rehabilitation Act § 504.

## Decision

- The Supreme Court reversed the Eighth Circuit.
- Punitive damages are not available in private suits under ADA § 202 and Rehabilitation Act § 504.
- Remedies under ADA § 202 and Rehabilitation Act § 504 are coextensive with those available under Title VI.
- Under the Spending Clause framework applicable to Title VI, “appropriate relief” is limited to remedies for which funding recipients are on notice when they accept federal funds.
- Because punitive damages are generally not available for breach of contract and are not expressly authorized, recipients are not on notice of exposure to punitive damages.

## Legal Principles

- When a statute operates under the Spending Clause, available monetary remedies are defined using a contract-law analogy, based on what the funding recipient can be understood to have accepted as a condition of federal funds.
- A remedy qualifies as “appropriate relief” only if the recipient had clear notice, at the time of accepting funds, that it could be liable for that remedy.
- ADA § 202 and Rehabilitation Act § 504 incorporate Title VI’s remedial framework; thus, their remedies do not extend beyond what Title VI permits under the Spending Clause notice rule.
- Punitive damages are generally unavailable in contract actions and therefore are not presumed to be among the remedies accepted by recipients of federal funds under Title VI-based conditions.
- A general presumption favoring “appropriate relief” for federal rights does not override the Spending Clause notice limitation on remedies.

## Conclusion

The Court held that punitive damages cannot be awarded in private actions under ADA § 202 and Rehabilitation Act § 504 because those provisions borrow Title VI’s Spending Clause remedial model, which limits relief to remedies for which federal-funds recipients had clear notice—excluding punitive damages absent express authorization.


Barnes v. Gorman, 536 U.S. 181 (2002)